Net Zero Company Benchmark: Frequently Asked Questions

The Climate Action 100+ Net Zero Company Benchmark assesses the performance of focus companies against the initiative’s three high-level goals: emissions reduction, governance, and disclosure. The Benchmark draws on distinct analytical methodologies and data sets to provide investors and other stakeholders with a robust tool to facilitate focus company engagement and action.

These FAQs have been updated as of March 2022 to reflect the most recent Benchmark iteration:

FREQUENTLY ASKED QUESTIONS

The Climate Action 100+ Net Zero Company Benchmark (“the Benchmark”) provides an objective way of measuring company progress against the initiative’s three high-level goals: emissions reduction, governance, and disclosure. The Benchmark tracks business alignment with a net zero emissions future and the Paris Agreement goal of limiting global temperature rise to 1.5°C against a number of key disclosure indicators and alignment assessments.

The indicators and assessments draw on unique analytical methodologies and data sets, which evaluate how focus companies are addressing climate change risks and provide greater insight for investors on companies’ transition to net zero emissions business models. The types of indicators and assessments can be broadly set into two categories, which form a dual approach to evaluating corporate progress against the Climate Action 100+ agenda.

 

Disclosure Framework indicators evaluate the adequacy of corporate disclosure (with the exception of metrics 2.3, 3.3 and 4.3 which assesses alignment with these disclosures). Alignment Assessments focus on evaluating the alignment of company actions with the Paris Agreement goals.

 

For more information, download the supporting methodology and framework documents.

To assist in their engagements with companies, signatories can use the Benchmark for:

 

 Monitoring company progress: The Benchmark reinforces and clarifies expectations for what companies need to do to align with the Climate Action 100+ goals and a 1.5°C net zero future, and provides a mechanism for tracking progress.

 

• Decision making on engagement strategies: The results of company assessments can be used by signatories to inform their actions during engagement cycles, such as decisions on voting or other engagement tactics.

 

• Assessing alignment or misalignment: Benchmark assessments can be used by investors to assess alignment between companies’ stated decarbonisation ambitions and their planned or actual decarbonisation investments and activities.

The need for higher company ambition on climate change was emphasised by Climate Action 100+ signatories following the October 2018 release of the Intergovernmental Panel on Climate Change’s (IPCC) Special Report on the Impacts of Global Warming of 1.5°C. This demonstrated the direct and immediate benefits of limiting global warming to 1.5°C for both society and the economy and supported growing awareness of the important role that private sector leaders play in achieving this goal.  

 

Limiting global warming to 1.5°C entails an ambitious and urgent global reduction in greenhouse gas (GHG) emissions by about 45% by 2030 (compared to 2010 levels), and net zero emissions by 2050 or sooner. Focusing on 166 of the world’s highest corporate emitters, the Climate Action 100+ Net Zero Company Benchmark sets a standard from which the level of ambition in companies’ climate strategies can be measured, and provides a framework from which signatories can develop targeted engagement approaches where company actions are inconsistent with limiting global warming to 1.5°C. 

 

Climate Action 100+ recognises the collective sector action necessitated by the goal of limiting global warming to 1.5°C; rather than focusing singularly on individual company action, engagement must also consider the corporate landscape and sectoral context within which a company operates. The latest climate science and scenarios increasingly indicate that the necessary time frame for companies to achieve net zero GHG emissions differs depending on the sector. For example, companies in certain sectors, such as electric utilities, may be expected to set more ambitious goals in order to achieve net zero emissions prior to 2050. As the aim of the Climate Action Net Zero Company Benchmark is to set an overarching standard for companies across sectors, the assessments included within it are, in general, sector neutral.  

 

We encourage those interested in how the high-level ambition of the Climate Action Net Zero Company Benchmark can be applied at a more sector-specific level to consider the more detailed guidance outlined within the initiative’s Global Sector Strategies. 

The first company assessments were released in March 2021. These have become a widely cited tool for assessing company progress towards a net zero emissions future. The second set of company assessments was released in March 2022. To learn more, explore the Benchmark’s background and future development.

Disclosure Framework: There have been updates to the methodology used for the March 2022 Disclosure Framework company assessments to reflect the evolving priorities of investors and the latest available climate science. While relatively minor, the changes to certain indicator methodologies may have an impact on some year-on-year company performance. 

 

Alignment Assessments: The March 2022 iteration contains additional Alignment Assessments (formerly known as ‘Capital Allocation Assessment Indicators’). These include: 

 

InfluenceMap’s ‘Organisation Scores’ and ‘Relationship Scores’, which assess focus companies’ direct and indirect climate policy engagement activities, respectively. 

 

Assessments from 2 Degrees Investing Initiative (2DII) measuring the emissions intensities of companies in three additional sectors (steel, cement, and aviation) against reference climate scenarios. 

 

A new provisional assessment from Carbon Tracker Initiative (CTI) and the Climate Accounting and Audit Project (CAAP) focused on focus companies’ climate accounting and audit practices.  

 

All other alignment assessments from CTI and 2DII contained in the March 2021 iteration of the Benchmark will remain the same. 

 

Download the methodologies for the March 2022 company assessments to learn more.

First set of company assessments against the Disclosure Framework (March 2021): The first set of company assessments reference disclosure-based data as of 22 January 2021.  

 

Second set of company assessments against the Disclosure Framework (March 2022): Individual company assessments use disclosure-based data as of 31 December 2021. TPI prepared preliminary assessments using public data collected up until mid-November 2021. A company review period was then held, starting 1 December 2021. Companies were invited to review these, correct any inaccuracies, and submit additional public disclosures up until 31 December 2021. Company disclosures beyond 31 December 2021 were not included in the March 2022 assessments, but will be considered for future company assessments.  

 

The Alignment Assessments follow unique data collection periods. Download their respective methodologies to learn more.

References to new and relevant company disclosures are published on a quarterly basis in the ‘Notes’ section at the bottom of each focus company’s Disclosure Framework assessment.  These new disclosures have not been formally assessed and are presented as supplementary, unaudited information, allowing for visibility into recent company progress. While these disclosures may be considered in future iterations of the Benchmark, they will have no effect on the official Benchmark outcome for the previous iteration.

Yes. A preliminary copy of the most recent Benchmark framework and methodologies are sent to all focus companies to communicate revisions or updates. Preliminary assessment against the Disclosure Framework are also sent to all focus companies ahead of publication as part of the company review period, when focus companies are invited to provide feedback on individual assessments and flag any inaccuracies. Final assessments are also shared with focus companies as a courtesy prior to launch. 

Whilst the overall objectives and framework will remain broadly consistent, we expect the Benchmark to continue to evolve to reflect investor priorities around accelerating the net zero emissions transition. In a fast-moving world of scientific updates, we want to ensure the Benchmark is rooted in the latest and most relevant climate science 

 

Some potential priorities for inclusion and refinement in future iterations of the Benchmark include (but are not limited to): 

 

Absolute Emissions: The latest climate science indicates that absolute global emissions must decline at an incremental rate of nearly 8 percent each year until 2030 in order to hold global warming to 1.5°C. Future iterations of the Benchmark may therefore explore indicators, metrics, and assessments to track trends in companies’ absolute emissions levels. 

 

1.5°C Scenario: As the International Energy Agency’s (IEA)’s Net Zero Emissions by 2050 Scenario (NZE) is currently only available for companies in a select number of sectors, the Benchmark will seek to assess all focus companies’ carbon performance against a net zero emissions by 2050 scenario, as and when the necessary data become available. In addition, future iterations of the Benchmark may incorporate more alignment assessments to evaluate focus companies’ activities and business plans against the IEA’s NZE. 

 

Expanded sector alignment methodologies: At present there are not sufficient methodologies available to assess greenhouse gas (GHG) target alignment for companies in certain sectors, including chemicals, coal mining, oil and gas distribution, consumer goods and services, other industrials, and other transport. Climate Action 100+ investor networks and our data partners will seek to develop these for future iterations of the Benchmark. 

 

Climate accounting and audit: In line with opinions from IASB and IAASB, the March 2022 iteration of the Benchmark incorporates a provisional assessment to evaluate whether a company’s accounting practices and related disclosures reflect the effects of climate risk and the global move onto a 2050 (or sooner) net zero emissions pathway. Following the release of the March 2022 Benchmark, further consultations and development of this assessment may occur.  

 

Just transition: The March 2022 iteration of the Benchmark contains a new Disclosure Framework ‘beta’ indicator which evaluates whether focus companies are incorporating the effects of the net zero transition on their workers and communities into their decarbonisation strategies. Companies were not publicly assessed, but the initiative will collect data to inform future development and consultations on this indicator.  

 

Expanded green revenue indicator: The current framework uses a ‘green revenues’ definition that aligns with the European Union’s (EU) Green Taxonomy criteria on ‘turnover’ (or revenues) for companies headquartered in the EU (as well as the UK, Switzerland and Norway). Companies headquartered outside of these regions are not being assessed in the 2021 and 2022 iterations of the Benchmark. Future iterations of this indicator may assess non-EU companies using appropriate green revenue classification systems and/or regional taxonomies where available. 

 

Offsets: Given questions about the quality and availability of offsets as well as concerns about excessive use of offsets in company decarbonisation plans, the initiative is currently researching this issue and may seek to develop new indicators, metrics, and alignment assessments to evaluate the transparency and credibility of company offsetting strategies.  

 

Consultations on the Benchmark framework and the timing of future iterations will be announced in due course. General feedback and questions are welcomed at [email protected]. 

Investors, companies, NGOs, and other relevant stakeholders will continue to be consulted on changes to the Benchmark framework and methodologies. Climate Action 100+ intends to hold a comprehensive public consultation at a later date so that investors, companies, NGOs, and other stakeholders can continue to provide input toward future direction and scoring methodologies. 

 

If you have any further general comments, questions or feedback, please get in touch via [email protected]. 

The Benchmark compiles data from a range of providers that make up the Climate Action 100+ Technical Advisory Group (TAG). The TAG is a group of select organisations that provide the initiative with technical expertise along with research and analysis to assess companies’ preparedness for the transition to a net zero emissions economy. They include the Transition Pathway Initiative (TPI), 2 Degrees Investing Initiative (2DII), Carbon Tracker Initiative (CTI) and InfluenceMap (IM). The Benchmark is not a disclosure mechanism or database itself, rather an assessment tool. 

 

The Benchmark indicators and assessments can be broadly separated into two categories: the Disclosure Framework and Alignment Assessments:

 

Disclosure Framework

 

The Disclosure Framework assessed by TPI draws on public and self-disclosed data from companies. These are collected from sources such as company annual reports, sustainability reports, press releases, and CDP disclosures, and provide an insight into the publicly stated aims and commitments that a company has made. The exact data source for each metric is not provided in the public company profiles. With the exception of metrics 2.3, 3.3 and 4.3, the Disclosure Framework does not assess a company’s alignment with the targets they have set out to achieve, nor how realistic the stated targets are given their current business activities and spending. It simply evaluates whether the company has disclosed key components of a credible decarbonisation strategy. 

 

The elements of the Disclosure Framework are structured as follows: 

 

Indicator: Specific area the company is being assessed on (e.g. Indicator 8 evaluates companies on climate governance).  

 

Sub-indicator: Component of indicator that divides it into specific areas of interest (e.g. Sub-indicator 8.2 evaluates executive remuneration).  

 

Metric: Highest resolution assessment that separates sub-indicators into components, creating the opportunity for evaluation across the subject of attention (e.g. Metric 8.2.b focuses on progress against climate change targets as a KPI to executive remuneration) 

 

Company disclosures related to the Disclosure Framework are assessed by TPI, with each metric of the framework given either ‘Yes’ or ‘No’.  The overarching sub-indicators and indicators are assessed on a ‘Yes’/’No’/’Partial’ basis (or ‘Not Applicable’/’Not Assessed’ where relevant).  

 

Download the full methodology and framework to learn more.

 

Alignment Assessments

 

Alignment Assessments (formerly called ‘Capital Allocation Assessment Indicators’) are provided by the initiative’s Technical Advisory Group members (aside from TPI) and compliment the Disclosure Framework. They provide independent evaluations of the alignment and adequacy of company actions with the goals of Climate Action 100+ and the Paris Agreement. 

 

These assessments consider data from a variety of sources, which differs depending on the assessment type. Download the methodologies from CTI, 2DII, and IM to learn more. 

The Benchmark does not specifically seek to score or rank companies, nor does it use overall numeric or alphabetic ratings. As every component of the Benchmark is important, the intent is to ensure that investors and other stakeholders give all indicators, sub-indicators, metrics, and alignment assessments due consideration, rather than focusing on overall rankings or scores. Company assessments are intended to draw investor attention to the most significant aspects of corporate strategy and a company’s climate action or inaction. Some indicators may have greater relevance for certain companies, sectorsor regions than others. For example, only companies in certain sectors are currently assessed on Sub-indicators 2.3, 3.3, and 4.3, and Sub-indicator 5.2 is only applicable to companies headquartered in Europe.  

The Net Zero Company Benchmark Disclosure Framework provides a sector-neutral set of indicators and assessments that measures the net zero transition readiness of companies across the globe. It sets out key elements of a credible decarbonisation strategy that are relevant to all companies. Therefore, the Disclosure Framework does not typically tailor indicators to individual sectors or regions.  

 

Climate Action 100+ recognises the nuances presented by different sectors and regions included within the Benchmark and the need for a deeper level of specificity in our engagements with companies. Some of these nuances are highlighted within the ‘Notes’ section of each company scorecard. However, to further aid signatories in encouraging focus companies to meet the goals of the initiative, Climate Action 100+ is also developing Global Sector Strategies for key carbon-intensive industries, which identify sector-specific priority actions that companies need to take to reach net zero emissions by 2050 or sooner. 

An additional note about whether Asian companies’ emissions reduction targets align to their home country NDCs was added to relevant company Benchmark profiles in March 2021 with the understanding that many companies operating under Asian jurisdictions are under the directive of their home country NDCs. This note compared each country’s NDC (based on their latest submission to the UNFCCC) against the most recent publicly announced (including to CDP) carbon reduction goals of the relevant companies. 

 

The initiative adopted 2030 (as specified in NDCs) as the timeframe against which companies’ emissions reductions targets were measured. Therefore, companies that had declared 2050 net zero targets but not set 2030 targets were assessed as not aligned.  

 

With the subsequent announcement by many Asian countries of updated NDCs seeking net zero emissions alignment, this note was deemed unnecessary and will therefore no longer be included in future iterations of the Benchmark. 

Nearly every indicator within the Disclosure Framework references companies’ degree of commitment to the higher-ambition goals of the Paris Agreement (i.e. limiting global warming to 1.5°C). For example; Indicator 1 assesses whether companies have committed to net zero emissions by 2050, which is the level of ambition the IPCC says is necessary to limit global warming to 1.5 degrees Celsius; Benchmark metrics 2.3, 3.3 and 4.3 explicitly assess company emissions alignment against 1.5°C scenarios (or close approximations thereto); Indicator 6 looks at whether the company has a commitment to align its capital allocation to 1.5°C; Indicator 7 looks at whether the company lobbies in line with the Paris Agreement and Indicator 10 looks at whether companies include a 1.5° C scenario in their quantitative climate-related scenario analysis.

 

Specifically relating to metrics 2.3, 3.3, and 4.3 of the Disclosure Framework, the March 2022 iteration of the Net Zero Company Benchmark assesses companies against the International Energy Agency’s (IEA) Net Zero Emissions by 2050 scenario(NZE) released in May 2021, for sectors where data is available. This sets out a pathway to reach net zero emissions by mid-century and keep the global temperature rise to 1.5°C with a 50% probability.​ NZE is only available for certain sectors and therefore some of the emission reduction target alignments continue to be determined against the pathways used in 2021.   

 

For assessments released in March 2021, companies’ emissions reduction targets were assessed against TPI scenarios largely reflecting the IEA’s reference scenarios for available sectors (with the exception of the automobile sector which is based on scenario data provided by the ICCT). B2DS is a rapid-transition scenario equivalent to an estimated 1.6°C of global warming in this century with net zero emissions reached by 2060 (with an approximate 50% chance).  

 

In addition, many of the Alignment Assessments evaluate company actions with reference to holding global warming to 1.5°C. The initiative’s ultimate goal is to integrate the NZE for all sectors assessed by the Benchmark, as and when the necessary data becomes available. 

The Benchmark Disclosure Framework and TPI’s methodology to assess focus company alignment with global climate scenarios are derived from the absolute emissions pathways and total carbon budgets developed by the International Energy Agency (IEA). Performance is described in intensity terms to allow for comparisons between companies and to eliminate the size differences between companies. For example, if a large company reduces its emissions by a certain absolute amount, it might represent only a relatively small portion of the company’s overall emissions impact, whereas if a smaller company were to reduce its absolute emissions by the exact same amount, it may represent a much greater effort given the company’s size and emissions impact. Using emissions intensity as the metric of performance better accounts for the difference in scale between companies and thereby enhances the comparability of company emissions reduction targets. Download the framework and methodologies  to learn more. 

 

In the longer term, the investor networks that coordinate Climate Action 100+ may consider integrating more features to measure and compare absolute emissions trends.  

Scope 3 applicability (i.e. which Scope 3 categories are deemed applicable for a given company) is determined on a sector level and based on consultation with climate experts, investor signatories and investor networks.

 

Generally speaking, the classification system outlined below, which is in accordance with the Greenhouse Gas (GHG) Protocol, applies:

 

ClusterSectorScope 3 applicable?
EnergyOil and gasYes (use of sold products)
Oil and gas distributionYes (use of sold products)
Electric utilitiesUtilities w/ oil and gas distribution businesses (use of sold products from distribution businesses)
Coal miningYes (use of sold products)
TransportAutosYes (use of sold products)
AirlinesNo
ShippingNo
Other transportYes (use of sold products)
IndustrialsAluminumNo
CementNo
SteelNo
ChemicalsYes (purchased goods and services and use of sold products)
PaperNo
Diversified MiningYes (processing of sold products; for coal manufacturers, also use of sold products)
Other industrialsOn a case by case basis (non-electricity use of sold product)
Consumer goods and servicesConsumer goods and servicesYes (purchased goods and services)

 

There may be some exceptions where companies do not fit into the classification system above and in these cases the Scope 3 applicability is decided along with the lead investors on a case-by-case basis.

The Disclosure Framework of the Benchmark identifies key elements that should be included in any company’s decarbonisation strategy. It is sector and region neutral.

 

As part of the Alignment Assessments, third-party data providers offer independent evaluations of the adequacy of company actions vis-a-vis their disclosures. These provide insights into any contrasts between what companies say in their disclosures versus what they do in practice.

 

The investor networks that coordinate Climate Action 100+ recognise that the adequacy of company decarbonisation strategies may strongly depend on the company’s sector or region. Therefore, when assessing the credibility of such strategies, investors and other stakeholders are encouraged use other sector-specific climate transition plan tools, such as the Climate Action 100+ Global Sector Strategies, in combination with the Benchmark.

 

Additional sector-specific alignment assessments may be considered for future iterations of the Benchmark (where feasible and available). Download the framework and methodologies  to learn more.

Offsets are explicitly referred to in the methodology guidance for Sub-indicator 5.1 of the Disclosure Framework, which asks that any decarbonisation strategy “clearly identifies the set of actions the company will implement to achieve its decarbonisation targets (such as phasing out carbon intensive products or assets, developing or deploying low carbon technologies, decarbonising supply chains or using offsets).”   

 

There is currently no agreed methodology to integrate offsets into sectoral assessment methodologies. All TPI benchmarks represent the transition efforts that individual sectors have to make themselves, independent of the use of offsets. 2DII and CTI do not include offsets in their models.  

 

The investor networks that coordinate Climate Action 100+ are of the view that the use of offsetting or carbon credits should be avoided and limited, if applied at all. Offsetting or ‘carbon dioxide removal’ should not be used by companies operating in sectors where viable decarbonisation technologies exist. For example, offsetting would not be considered credible if used to offset emissions for a coal-fired power plant because viable alternatives exist to coal-fired power plants. 

 

Companies are encouraged to be transparent about how they use offsets, and to clearly delineate between their own emission reduction efforts and the emission reductions delivered through offsets. This transparency also allows Climate Action 100+ to revisit company assessments as the collective thinking on offsets evolves.  

 

Offsets will be an area for future development in the Benchmark.  

This information is in the process of being updated to reflect the most up-to-date methodologies used in the Benchmark and used by the Science Based Targets initiative.  

 

The Disclosure Framework of the Climate Action 100+ Net Zero Company Benchmark (specifically, metrics 2.3, 3.3, and 4.3) assesses companies’ publicly disclosed greenhouse gas (GHG) emissions reduction targets using the Transition Pathway Initiative’s Carbon Performance methodology. This is based on the Sectoral Decarbonisation Approach (SDA), a framework that translates GHG emissions targets made at the international level into appropriate sector-level benchmarks, against which the performance of individual companies can be compared. The Science Based Targets Initiative (SBTi) similarly provides an SDA-based alignment approach for some sectors but does not require companies to use the SDA-based approach (for example, it also has a sector-agnostic approach and an economic intensity approach).  

  

Whilst some company targets set via SBTi may be recognised in the Benchmark and help to assess companies positively on certain indicators, this is not automatically the case. Targets need to meet the criteria of the Benchmark, specifically with regards to:  

  

Timeframes – The Benchmark categorises and assesses targets across three time horizons: long-term (2036-2050), medium-term (2026-2035) and short-term (2020-2025); in addition to a net zero 2050 ambition indicator.  By contrast, science-based targets must cover a minimum of 5 years and a maximum of 15 years from the date the target is submitted to the SBTi for validation.   

  

Emissions coverage – The Benchmark categorises and assesses targets by: scope 1 and 2 emissions (at least 95%), and most relevant scope 3 emissions (where applicable). By contrast, for SBTi, Scope 3 emissions only need to be included in the target if they account for more than 40% of the company’s total emissions profile (and only 2/3 of the Scope 3 emissions need to be included in the target if this is the case).  

  

Data sources – The Benchmark uses publicly disclosed information such as company annual reports, financial filings, CDP disclosures, etc. Targets therefore need to be disclosed by companies through their own corporate reporting, or through CDP, in order to be recognised. By contrast, SBTi has its own submission and evaluation process that it uses to review and validate company emissions targets.   

  

See framework and methodologiesfor more information. Also see the latest  SBTi criteria and recommendations. 

This information is in the process of being updated to reflect the most up-to-date information.

 

The design of the Benchmark indicators (in particular those that relate to emissions targets and performance) has, where feasible, sought to build on existing disclosure frameworks such as those produced by TCFD, CDP, SASB, and GRI, among others. The Benchmark is designed to complement these frameworks and provide more detail on specific disclosures that investors want to see regarding how companies are planning to transform their businesses in line with a net zero emissions future. 

The Benchmark has an explicit indicator (Indicator 10 of the Disclosure Framework) on the implementation of TCFD aligned disclosure, which is a key goal of Climate Action 100+. The TCFD offers companies and investors a comprehensive, forward-looking framework to assess climate-related risks and opportunities. 

 

The Climate Action 100+ Net-Zero Company Benchmark is not a reporting mechanism itself and draws on existing disclosure platforms (e.g., CDP) and other public information such as a company’s annual report, sustainability report, press releases, etc. This captures any publicly available information prepared using frameworks such as TCFD, SASB, GRI, etc.  

This information is in the process of being updated to reflect the most up-to-date information.

 

The Transition Pathway Initiative  (TPI) is an investor-supported tool that assesses companies’ management quality and carbon performance. Whilst TPI is providing the data that underpins the Disclosure Framework of the Climate Action 100+ Net Zero Company Benchmark, TPI also has an independent (but closely linked) framework. TPI’s framework provides a number of other data points and indicators that are helpful to investor engagement, in particular for companies that are at the early stages of managing climate change. TPI also covers a wider universe of companies than Climate Action 100+, with an online toolkit that allows for peer comparison of companies by sector. 

 

For more information, please refer to this investor guide  on how the Benchmark and TPI tools can be used together. Although the guide has a focus on supporting engagement in Asia, it is generally applicable across regions. 

Next round of assessments

Climate Action 100+ is fully committed to driving meaningful change on net zero and tackling the systemic risk of climate change. While it’s clear that important progress has been made on a number of areas in the March 2022 Net Zero Company Benchmark assessments, it is also apparent we need to see action taken further and more quickly to limit global warming to 1.5°C and thereby avoid some of the worst impacts of climate change. The initiative plans to publish its third round of Benchmark assessments later this year. This will give focus companies another opportunity to step up and demonstrate progress by providing additional disclosures or commitments, announced since 1 January 2022, between 12 April and 13 May to improve their March 2022 Benchmark results.

There will be no changes to the Climate Action 100+ Net Zero Company Benchmark framework between the March 2022 assessments and those released later in 2022. This will provide consistency between the two iterations.

On 12 April, focus companies were invited to notify the initiative of any relevant commitments and disclosures that are not reflected in their final March 2022 Benchmark assessments and which they believe could improve their scores. The deadline for company responses will be 13 May. Companies must respond during the review period in order to have their assessments updated. There will be no exceptions or extensions after the deadline. The initiative expects to send companies their final scorecards as a courtesy approximately two weeks before publication.

Climate Action 100+ expects to see updates to both the Disclosure Framework as well as the Alignment Assessments. However, only the March 2022 Disclosure Framework scores provided by the Transition Pathway Initiative and FTSE Russell will be subject to the 12 April-13 May company review period. The Alignment Assessments provided by Carbon Tracker Initiative, 2 Degrees Investing Initiative, and InfluenceMap each have their own unique processes and assessment methodologies.